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BMU: no own take-back in trade

In the opinion of the German Federal Ministry for the Environment (BMU), DM's pilot project to take back plastic bottles is not permissible.


We reported on the pilot project of the drugstore DM to take back empty plastic bottles in 150 stores in the Karlsruhe and Munich areas (see news of October 6, 2021). Now, according to a report in Euwid, the German Federal Ministry for the Environment (BMU) has rejected such a voluntary take-back of retail packaging. The packing law would not give such a taking back. On the contrary, it conclusively regulated product responsibility in the form that packaging subject to system participation must either participate in a dual system or be taken back by way of an industry solution, which must first be notified to the Central Agency Packaging Register (ZSVR). According to Euwid, industry circles as well as the BMU see a danger for the dual system in the voluntary take-back. Packaging that is easy to recycle would thus be removed from the packaging stream and the dual systems might not be able to meet the demanding recycling requirements of the Packaging Act. According to the BMU, the option of self-recovery, which was still included in the Packaging Ordinance and would be similar to voluntary recovery in many respects, was deliberately not included in the Packaging Act.

According to Euwid, the Ministry of the Environment of the state of Baden-Württemberg, which accompanied the review of the DM project, strongly disagrees with the BMU's view and does not see that the Packaging Act excluded voluntary take-back and, contrary to the BMU's view, left room for the application of §26 of the Closed Substance Cycle Waste Management Act. In addition, there was no obligation on the part of consumers to hand over sales packaging to the dual systems. The question of offsetting the quantities from voluntary take-back against the quotas was open. In addition, care had been taken to ensure that the project did not involve any ecological regression in relation to the requirements of the Packaging Act. On the contrary, he said, the relatively clean take-back was expected to result in significantly better quality and quantity of recycling.



  • Euwid Recycling und Entsorgung 42/2021 (10/19/2021)
  • Photo: © DM

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